SO ORDERED.

Quisumbing (Chairperson), Reyes, Leonardo-De Castro and

Brion, JJ., concur.
Judgment affirmed.
Notes.Suffice it to state that in the crime of rape, the testimony of
the victim and not the findings of the medico-legal officer, is the most
important element to prove that the felony had been committed. (People
vs. Bang-ayan, 502 SCRA 658 [2006])
To be sure, the law does not impose burden on the rape victim to
prove resistanceit is enough if the intercourse takes place against the
victims will. (People vs. Canare, 511 SCRA 31 [2006])
o0o

A.M. No. MTJ-07-1682.June 19, 2008.*

ESTER F. BARBERO, complainant, vs. JUDGE CESAR M.

DUMLAO, Municipal Trial Court, San Mateo, Isabela, respondent.
Criminal Procedure; Bail; Section 19, Rule 114 of the Rules of Court
provides that the accused must be discharged upon approval of the bail by
the judge with whom it was filed in accordance with Section 17.Section 3,
Rule 114 of the Rules of Court provides that no person under detention by
legal process shall be released except when he is admitted to bail. Section 19
provides that the accused must be discharged upon approval of the bail by the
judge with whom it was filed in accordance with Section 17. Section 17
provides that the bail may be filed with the court where the case is pending,
_______________
* EN BANC.

194

194

SUPREME COURT REPORTS ANNOTATED

Barbero vs. Dumlao

unless (1) the judge in that court is absent or unavailable, or (2) the accused
is arrested in a province, city, or municipality other than where the case is
pending. If the judge is absent or unavailable, the bail should be filed with
another branch of the same court. If the accused is arrested in a province,
city, or municipality other than where the case is pending, the bail should be
filed with any RTC of the place.
Courts; Judges; Judge Dumlao opted to ignore all of the Courts
directivesby his silence, Judge Dumlao admitted the truth of the
allegations.The Court directed Judge Dumlao several times to comment on
Barberos allegations. Judge Dumlao opted to ignore all of the Courts
directives. By his silence, Judge Dumlao admitted the truth of the allegations.
In Palon, Jr. v. Vallarta, 517 SCRA 624 (2007), the Court held that silence is
admission of the truth of the charges: Respondent judge failed to comment on
the complaint or file any responsive pleading or manifestation despite receipt
of notice to do so. x x x The natural instinct of man impels him to resist an
unfounded claim or imputation and defend himself. It is against human nature
to just remain reticent and say nothing in the face of false accusations. Hence,
silence x x x is an admission of the truth of the charges. Respondent
judge is deemed to have admitted the charges against him. (Emphasis
ours)
Same; Same; Bail; It is elementary that a municipal trial court judge
has no authority to grant bail to an accused arrested outside of his territorial
jurisdiction.In Lim v. Dumlao, 454 SCRA 196 (2005), the Court held that:
It is not disputed that the criminal cases filed by complainant against Herman
Medina were pending before the Regional Trial Court of Santiago City,
Isabela, Branch 35. In fact, the warrant of arrest was issued by Judge Fe
Albano Madrid, presiding judge of the said court. The order of release
therefore, on account of the posting of the bail, should have been issued by
that court, or in the absence or unavailability of Judge Madrid, by another
branch of an RTC in Santiago City. In this case, however, there is no proof
that Judge Madrid was absent or unavailable at the time of the posting of the
bail bond. In fact, complainant Lim avers that on the day [Judge Dumlao]
ordered the release of Medina, Judge Madrid and all the judges of the RTC of
Santiago City, Isabela were at their respective posts. It is elementary that a
municipal trial court judge has no authority to grant bail to an accused
195

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195

Barbero vs. Dumlao

arrested outside of his territorial jurisdiction. The requirements of
Section 17(a), Rule 114 x x x must be complied with before a judge may
grant bail. The Court recognizes that not every judicial error bespeaks
ignorance of the law and that, if committed in good faith, does not
warrant administrative sanction, but only in cases within the
parameters of tolerable misjudgment. Where x x x the law is
straightforward and the facts so evident, not to know it or to act as if
one does not know it constitutes gross ignorance of the law. [Judge
Dumlao] undeniably erred in approving the bail and issuing the order of
release. He is expected to know that certain requirements ought to be
complied with before he can approve Medinas bail and issue an order
for his release. The law involved is rudimentary that it leaves little
room for error. (Emphasis ours)
Same; Same; Same; The acts of approving bail and ordering the release
of accused whose cases are pending before other courts constitute gross
ignorance of the law.The acts of approving bail and ordering the release of
accused whose cases are pending before other courts constitute gross
ignorance of the law. Gross ignorance of the law is a serious offense
punishable by (1) dismissal from the service, forfeiture of all or part of the
benefits, except accrued leave credits, and disqualification from reinstatement
or appointment to any public office, including government-owned or
controlled corporations; (2) suspension from office without salary and other
benefits for more than three but not exceeding six months; or (3) a fine of
more than P20,000 but not exceeding P40,000.
Same; Same; Administrative Law; Court resolutions directing judges to
comment on administrative complaints are not mere requestsJudges are
duty-bound to obey them fully and promptly.Court resolutions directing
judges to comment on administrative complaints are not mere requests.
Judges are duty-bound to obey them fully and promptly. In refusing to
comment on the affidavit-complaint for almost five years and despite several
directives from the Court, Judge Dumlao blatantly demonstrated gross
misconduct, outright disrespect, indifference, and a recalcitrant streak in his
character.
Same; Same; A judge should perform official duties honestly, and with
impartiality and diligence.Aside from Lim, Pascual, and
196

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SUPREME COURT REPORTS ANNOTATED

Barbero vs. Dumlao

Office of the Court Administrator, Judge Dumlao has another administrative

case decided against him. In Morales, Sr. v. Judge Dumlao, 376 SCRA 573
(2002), the Court found him liable for violating SC Administrative Circular
No. 1-90. In that case, the Court held that: [Judge Dumlaos] claim that he
did not know how he inadvertently signed the notarized revocation of power
of attorney in this case betrays a deficiency of that degree of circumspection
demanded of all those who don the judicial robe. It is, in fact, an open
admission of his negligence and lack of care in attending to the incidents
brought before him for adjudication. This kind of judicial carelessness runs
contrary to Canon 3 of the Code of Judicial Conduct, which states that: A
judge should perform official duties honestly, and with impartiality and
diligence. [(Emphasis ours)]
Same; Same; Penalties; The Court will not hesitate to impose the
ultimate penalty for it cannot tolerate any conduct that diminishes the faith of
the people in the judicial system.Judge Dumlao has amply demonstrated his
incorrigibility and unfitness to be a judge. He is undeterred by the several
penalties and stern warnings the Court has given him. The Court will not
hesitate to impose the ultimate penalty for it cannot tolerate any conduct that
diminishes the faith of the people in the judicial system.

ADMINISTRATIVE MATTER in the Supreme Court. Gross Ignorance

of the Law.
The facts are stated in the opinion of the Court.
PER CURIAM:
This is a complaint for gross ignorance of the law filed by Ester F.
Barbero (Barbero) against Judge Cesar M. Dumlao (Judge Dumlao),
Presiding Judge of the Municipal Trial Court, San Mateo, Isabela.
Barbero filed a criminal case1 for estafa against a certain Herman A.
Medina (Medina). The case was raffled to Judge Anastacio D. Anghad
(Judge Anghad), Presiding Judge of the
_______________
1 Docketed as Criminal Case No. 36-4142, entitled The People of the
Philippines v. Herman Medina.
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Barbero vs. Dumlao

Regional Trial Court (RTC), Judicial Region II, Branch 36, Santiago City,
Isabela. On 19 February 2003, Judge Anghad issued a warrant of arrest2

commanding the proper officer to arrest Medina.

Medina was arrested by virtue of the warrant of arrest. However,
Judge Dumlao approved Medinas bail and, on 9 May 2003, issued an
order3 commanding the Bureau of Jail Management and Penology and
the Philippine National Police to release Medina. Barbero alleged that
Judge Dumlaos approval of Medinas bail and his order to release
Medina were unlawful.
On 15 July 2003, the Office of the Court Administrator (OCA)
received an affidavit-complaint4 from Barbero charging Judge Dumlao
with gross ignorance of the law. In its 1st Indorsement5 dated 7 August
2003, the OCA directed Judge Dumlao to comment on the affidavitcomplaint. Judge Dumlao ignored the 1st Indorsement. In its 1st Tracer6
dated 11 November 2003, the OCA directed Judge Dumlao to comment
on the affidavit-complaint. Judge Dumlao ignored the 1st Tracer. In its
2nd Tracer7 dated 10 March 2004, the OCA directed Judge Dumlao to
comment on the affidavit-complaint. Judge Dumlao ignored the 2nd
Tracer. In a Resolution8 dated 6 April 2005, the Court directed Judge
Dumlao to comment on the affidavit-complaint and to show cause why he
should not be administratively dealt with for ignoring the OCAs
directives. Judge Dumlao ignored the 6 April 2005 Resolution.
_______________
2 Rollo, p. 3.
3 Id., at p. 4.
4 Id., at pp. 1-2.
5 Id., at p. 7.
6 Id., at p. 10.
7 Id., at p. 11.
8 Id., at p. 18.
198

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SUPREME COURT REPORTS ANNOTATED

Barbero vs. Dumlao

In a Resolution9 dated 17 August 2005, the Court reiterated its 6

April 2005 Resolution. Judge Dumlao ignored the 17 August 2005
Resolution. In a Resolution dated 6 February 2006, the Court fined
Judge Dumlao P500 for ignoring its directives and directed Judge Dumlao
to comply with the 17 August 2005 Resolution. Judge Dumlao ignored
the 6 February 2006 Resolution. In Resolutions dated 18 September
2006 and 19 February 2007, the Court considered Judge Dumlao to
have waived his right to comment on the affidavit-complaint and resolved
to proceed with the administrative case based on the pleadings already

filed.
The Court finds Judge Dumlao liable for gross ignorance of the law
and for violation of Court directives.
Section 17(a), Rule 114 of the Rules of Court provides:
SEC.17.Bail, where filed.(a)Bail in the amount fixed may be filed
with the court where the case is pending, or in the absence or unavailability of
the judge thereof, with any regional trial judge, metropolitan trial judge,
municipal trial judge, or municipal circuit trial judge in the province, city, or
municipality. If the accused is arrested in a province, city, or municipality
other than where the case is pending, bail may also be filed with any regional
trial court of said place, or if no judge thereof is available, with any
metropolitan trial judge, municipal trial judge, or municipal circuit trial judge
therein.

In Cruz v. Judge Yaneza,10 the Court held that:

There are prerequisites to be complied with. First, the application for bail
must be filed in the court where the case is pending. In the absence or
unavailability of the judge thereof, the application for bail must be filed with
another branch of the same court within the province or city. Second, if
the accused is arrested in a province, city or municipality other than where
the case is pending, bail may be filed with any regional trial court of the
place. (Emphasis ours)
_______________
9 Id., at p. 20.
10 363 Phil. 629, 644; 304 SCRA 285, 299 (1999).
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Barbero vs. Dumlao

The criminal case Barbero filed against Medina was pending before
the RTC of Santiago City. Judge Anghad of the RTC issued the warrant
of arrest, and Medina was arrested by virtue of that warrant.
Section 3, Rule 114 of the Rules of Court provides that no person
under detention by legal process shall be released except when he is
admitted to bail. Section 19 provides that the accused must be
discharged upon approval of the bail by the judge with whom it was filed
in accordance with Section 17. Section 17 provides that the bail may be
filed with the court where the case is pending, unless (1) the judge in
that court is absent or unavailable, or (2) the accused is arrested in a
province, city, or municipality other than where the case is pending. If the

judge is absent or unavailable, the bail should be filed with another

branch of the same court. If the accused is arrested in a province, city,
or municipality other than where the case is pending, the bail should be
filed with any RTC of the place.
In the present case, there was no showing that Judge Anghad was
absent or unavailable or that Medina was arrested outside Santiago City.
Thus, Medinas bail should have been filed with Judge Anghad. Even if
Judge Anghad were absent or unavailable or even if Medina were
arrested in San Mateo, Judge Dumlao would still be liable because the
bail should have been filed with another branch of the RTC in Santiago
City or with the RTC of San Mateo, respectively.11
Since the criminal case was pending before the RTC of Santiago City
and there was no showing that Judge Anghad of the RTC was absent or
unavailable, Judge Dumlao lacked authority to approve the bail and order
Medinas release.
_______________
11 De Leon v. Corpuz, A.M. No. RTJ-03-1780, 14 September 2005, 469 SCRA
624, 627-629; Inoturan v. Limsiaco, Jr., A.M. No. MTJ-01-1362, 6 May 2005, 458
SCRA 48, 55; Lim v. Dumlao, A.M. No. MTJ-04-1556, 31 March 2005, 454 SCRA
196, 201; Adapon v. Domagtoy, A.M. No. MTJ-96-1112, 27 December 1996, 265
SCRA 824, 830-831.
200

200

SUPREME COURT REPORTS ANNOTATED

Barbero vs. Dumlao

Barbero alleged that Judge Dumlaos acts of approving Medinas bail

and ordering Medinas release were not in accordance with law:
[N]apag-alaman ko x x x na [si Medina] ay basta na lang pinakawalan ni x
x x Judge Cesar M. Dumlao ng Municipal Trial Court ng San Mateo, Isabela x
x x;
[A]ng ginawa ni Judge Cesar M. Dumlao ay hindi naaayon sa batas sapagkat
wala siyang kapangyarihang pakawalan x x x [si Medina];
[N]apag-alaman ko rin na ang pagrerelease na ginawa ni Judge Dumlao ay
base sa [bail] na ipinakita sa kanya;
[S]a akin pong pagkakaalam, lahat po ng [bail] sa criminal cases ay dapat
aksyunan at aprubahan ng hukom o judge na siyang may hawak ng asunto;
xxxx
[K]ung maaari po sana, dahil sa kawalang respeto [ni Judge] Cesar M.
Dumlao sa ating batas x x x, ipinakikiusap [ko] na sana ay imbestigahan ang
nasabing pagmamalabis at kawalan ng respeto[.]

The Court directed Judge Dumlao several times to comment on

Barberos allegations. Judge Dumlao opted to ignore all of the Courts
directives. By his silence, Judge Dumlao admitted the truth of the
allegations. In Palon, Jr. v. Vallarta,12 the Court held that silence is
admission of the truth of the charges:
Respondent judge failed to comment on the complaint or file any
responsive pleading or manifestation despite receipt of notice to do so. x x x
The natural instinct of man impels him to resist an unfounded claim or
imputation and defend himself. It is against human nature to just remain
reticent and say nothing in the face of false accusations. Hence, silence x x x
is an admission of the truth of the charges. Respondent judge is
deemed to have admitted the charges against him. (Emphasis ours)
_______________
12 A.M . No. M TJ-04-1530, 7 M arch 2007, 517 SCRA 624, 628.
201

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Barbero vs. Dumlao

This is the second time Judge Dumlao unlawfully approved the bail
and ordered the release of Medina. The instant case has exactly the same
set of facts as Lim v. Dumlao.13 In that case (1) complainant filed two
criminal cases for carnapping and theft against Medina; (2) the criminal
cases were filed with the RTC, Judicial Region II, Branch 35, Santiago
City, Isabela; (3) Judge Fe Albano Madrid of the RTC issued a warrant
of arrest against Medina; (4) Medina was arrested by virtue of the
warrant of arrest; (5) Judge Dumlao approved the bail of Medina; and
(6) Judge Dumlao ordered the release of Medina.
In Lim,14 the Court held that:
It is not disputed that the criminal cases filed by complainant against
Herman Medina were pending before the Regional Trial Court of Santiago
City, Isabela, Branch 35. In fact, the warrant of arrest was issued by Judge
Fe Albano Madrid, presiding judge of the said court. The order of release
therefore, on account of the posting of the bail, should have been issued by
that court, or in the absence or unavailability of Judge Madrid, by another
branch of an RTC in Santiago City. In this case, however, there is no proof
that Judge Madrid was absent or unavailable at the time of the posting of the
bail bond. In fact, complainant Lim avers that on the day [Judge Dumlao]
ordered the release of Medina, Judge Madrid and all the judges of the RTC of

Santiago City, Isabela were at their respective posts.

It is elementary that a municipal trial court judge has no authority
to grant bail to an accused arrested outside of his territorial
jurisdiction. The requirements of Section 17(a), Rule 114 x x x must be
complied with before a judge may grant bail. The Court recognizes that not
every judicial error bespeaks ignorance of the law and that, if
committed in good faith, does not warrant administrative sanction, but
only in cases within the parameters of tolerable misjudgment. Where x
x x the law is straightforward and the facts so evident, not to
_______________
13 Supra note 11 at pp. 201-202.
14 Id., at p. 202.
202

202

SUPREME COURT REPORTS ANNOTATED

Barbero vs. Dumlao

know it or to act as if one does not know it constitutes gross ignorance

of the law.
[Judge Dumlao] undeniably erred in approving the bail and issuing
the order of release. He is expected to know that certain requirements
ought to be complied with before he can approve Medinas bail and
issue an order for his release. The law involved is rudimentary that it
leaves little room for error. (Emphasis ours)

The acts of approving bail and ordering the release of accused whose
cases are pending before other courts constitute gross ignorance of the
law.15 Gross ignorance of the law is a serious offense16 punishable by (1)
dismissal from the service, forfeiture of all or part of the benefits, except
accrued leave credits, and disqualification from reinstatement or
appointment to any public office, including government-owned or
controlled corporations; (2) suspension from office without salary and
other benefits for more than three but not exceeding six months; or (3) a
fine of more than P20,000 but not exceeding P40,000.17
Aside from Lim, the Court also found Judge Dumlao grossly ignorant
of the law in Pascual v. Judge Dumlao.18 In that case, Judge Dumlao
(1) hastily ordered the issuance of a temporary restraining order (TRO)
without notice and hearing; (2) ordered the issuance of the TRO even
though there was no showing of any grave or irreparable injury; (3) hastily
granted a motion to deposit harvest without notice and hearing; and (4)
failed to order the sheriff to render an accounting of the harvest.
Canon 6 of the New Code of Judicial Conduct for the Philippine
Judiciary provides that competence is a prerequisite to

_______________
15 Espaol v. Mupas, A.M. No. MTJ-01-1348, 11 November 2004, 442 SCRA 13,
50.
16 Section 8, Rule 140 of the Rules of Court.
17 Section 11(A), Rule 140 of the Rules of Court.
18 414 Phil. 1, 10-13; 361 SCRA 478, 488 (2001).
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Barbero vs. Dumlao

the due performance of judicial office. Judge Dumlao lacks this
prerequisite.
Judge Dumlao disrespected the Court by repeatedly refusing to
comment on the affidavit-complaint. In its 1st Indorsement dated 7
August 2003, 1st Tracer dated 11 November 2003, and 2nd Tracer
dated 10 March 2004, the OCA directed Judge Dumlao to comment on
the affidavit-complaint. In its Resolutions dated 6 April 2005, 17 August
2005, and 6 February 2006, the Court fined Judge Dumlao P500,
directed him to comment on the affidavit-complaint, and directed him to
show cause why he should not be administratively dealt with for refusing
to comment. Judge Dumlao unjustifiably ignored all six directives.
Court resolutions directing judges to comment on administrative
complaints are not mere requests. Judges are duty-bound to obey them
fully and promptly.19 In refusing to comment on the affidavit-complaint for
almost five years and despite several directives from the Court, Judge
Dumlao blatantly demonstrated gross misconduct, outright disrespect,
indifference, and a recalcitrant streak in his character.20
This is the third time Judge Dumlao disrespected the Court. In Office
of the Court Administrator v. Dumlao,21 the Court found him liable for
ignoring its directives. In that case, the Court held that:
It appears that Judge Dumlao ignored and continued to ignore this
Courts directive requiring him to file his comment on complainant
Sinaon, Jr.s administrative complaint. He had been afforded more than ample
time within which to file the required pleading. x x x [S]everal Resolutions
had been issued by the OCA and this Court requiring Judge Dumlao to
comment on the complaint against him. The first Resolution was issued as
early as 2
_______________
19 Palon, Jr. v. Vallarta, supra note 12 at pp. 628-629.
20 Imbang v. Del Rosario, A.M . No. 03-1515-M TJ, 19 November 2004, 443 SCRA 79,

83-85.
21 A.M . No. M TJ-07-1679, 4 M arch 2008, 547 SCRA 531.
204

204

SUPREME COURT REPORTS ANNOTATED

Barbero vs. Dumlao

August 2002 and the last was issued almost three years later, or 5 July 2005,
by which time, the Court already deemed waived Judge Dumlaos right to file
his comment and considered the case submitted for decision based on the
pleadings filed. Subsequently, Judge Dumlao again failed to comply with the
order of this Court to file his manifestation in the re-docketed administrative
complaint (concerning his non-filing of the comment) despite due notice.
Judge Dumlao had been given more than ample time to abide with
the orders of this Court, yet he persistently failed to do so. Judge
Dumlao neither offered any reason nor raised any defense for his
failure to comply with the mandates of this Court. Nothing was heard
from Judge Dumlao as to what had prevented him from complying with
the Courts directives. Such insolence should not go unpunished.
(Emphasis ours)

In Lim,22 the Court also found Judge Dumlao liable for ignoring its
directives. In that case, the Court held that, We agree with the OCA that
[Judge Dumlao] must be held administratively liable for his unjustified
failure to comment on an administrative complaint. This constitutes gross
misconduct and insubordination.
Violation of Supreme Court directives is a less serious offense23
punishable by (1) suspension from office without salary and other benefits
for not less than one nor more than three months, or (2) a fine of more
than P10,000 but not exceeding P20,000.24
Aside from Lim, Pascual, and Office of the Court Administrator,
Judge Dumlao has another administrative case decided against him. In
Morales, Sr. v. Judge Dumlao,25 the Court found him liable for violating
SC Administrative Circular No. 1-90. In that case, the Court held that:
_______________
22 Supra note 11 at p. 204.
23 Section 9, Rule 140 of the Rules of Court.
24 Section 11(B), Rule 140 of the Rules of Court.
25 427 Phil. 56, 61-62; 376 SCRA 573, 577-578 (2002).
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Barbero vs. Dumlao

[Judge Dumlaos] claim that he did not know how he inadvertently
signed the notarized revocation of power of attorney in this case betrays a
deficiency of that degree of circumspection demanded of all those who don
the judicial robe. It is, in fact, an open admission of his negligence and lack of
care in attending to the incidents brought before him for adjudication. This
kind of judicial carelessness runs contrary to Canon 3 of the Code of Judicial
Conduct, which states that:
A judge should perform official duties honestly, and with
impartiality and diligence. [(Emphasis ours)]
While we do not expect judges to have an encyclopedic recollection of
applicable laws, jurisprudence or administrative circulars we issue periodically
in the discharge of their responsibilities, they nevertheless have the bounden
duty to keep abreast with the law and the changes therein as well as the
decisions of this Court. As a trial judge, [Judge Dumlao] is the visible
representation of law and justice. Under Canon 1.01 of the Code of Judicial
Conduct he is expected to be the embodiment of competence, integrity and
independence to maintain public confidence in the legal system.
Inefficient judges are equally impermissible in the judiciary as the
incompetent and dishonest ones. Any of them tarnishes the image of the
judiciary and brings it to public contempt, dishonor or disrespect and must
then be administratively dealt with and punished accordingly.

Judge Dumlao has amply demonstrated his incorrigibility and unfitness

to be a judge. He is undeterred by the several penalties and stern
warnings the Court has given him. The Court will not hesitate to impose
the ultimate penalty for it cannot tolerate any conduct that diminishes the
faith of the people in the judicial system.26
WHEREFORE, the Court finds Judge Cesar M. Dumlao, Municipal
Trial Court, San Mateo, Isabela, GUILTY of GROSS IGNORANCE
OF THE LAW and VIOLATION OF SUPREME COURT
DIRECTIVES. Accordingly, the Court
_______________
26 Escobar Vda. de Lopez v. Luna, A.M. No. P-04-1786, 13 February 2006, 482
SCRA 265, 277-278.
206

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SUPREME COURT REPORTS ANNOTATED

Barbero vs. Dumlao

DISMISSES him from the service, with forfeiture of all benefits except
accrued leave credits, and with prejudice to reinstatement or appointment
to any public office including government-owned or controlled
corporations.
SO ORDERED.
Puno (C.J.), Quisumbing, Ynares-Santiago, Carpio, Corona,
Azcuna, Tinga, Chico-Nazario, Velasco, Jr., Reyes, Leonardo-De
Castro and Brion, JJ., concur.
Austria-Martinez, Carpio-Morales and Nachura, JJ., On Official
Leave.
Judge Cesar M. Dumlao dismissed from service for gross
ignorance of the law, with forfeiture of all benefits except accrued
leave credits and, with prejudice to reinstatement or appointment to
any public office.
Notes.Lack of conversance with legal principles sufficiently basic
and elementary constitutes gross ignorance of the law. (Enriquez vs.
Caminade, 485 SCRA 98 [2006])
Respondent judges release on bail of the accused without priorly
conducting a hearing for the purpose, betrays his gross ignorance of the
law, it being settled that where the law involved is simple and elementary,
lack of observance thereof constitutes gross ignorance of the law.
(Enriquez vs. Sarmiento, Jr., 498 SCRA 6 [2006])
o0o

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